Germany should maintain salary band, role level, and exception criteria documented and separated from personal characteristics. Recommendation: make equal pay risks visible through reports, sampling, and outlier reviews in the portal. In practice: report on band deviations by role, location, and seniority. Limitation: market scarcity can objectively justify individual deviations, but they must not remain undocumented. (Sources: EU Directive 2023/970 Pay Transpare, Destatis Labour Market)
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